Legislative proposal for a controlled foreign companies regime in Poland from an international perspective

Magdalena Małgorzata Hybka, Poznan University of Economics, Department of Public Finance, Poznań, Poland

AbstractTackling corporate profit shifting requires appropriate anti-avoidance
measures. This article reviews one of these measures, a controlled
foreign companies (corporations) regime. It has been implemented in many
countries, in some of them as early as the 1960s. The need for its
introduction has also been expressed on many occasions by the Polish
legislator. The article is composed of three sections. The first
considers the reasons for the implementation of the analyzed regime. The
second describes the controlled foreign corporation legislation in the
USA and selected European Union member states. The last section is
devoted to a bill on taxing controlled foreign companies in Poland.